Sponsor licence update, October 2026: what employers must do now

Three separate changes landed on sponsors over the past year, and none of them were announced as a single reform. Taken together they change who you have to check, who can touch your Sponsorship Management System account, and what a sponsored hire costs. This is the short version, with the dates you can put in a diary.

1 October 2026: right to work checks go beyond employees

The right to work scheme used to stop at a contract of employment. From 1 October 2026 it also covers casual and temporary workers engaged under a worker's contract, individual sub-contractors, and online services that match service providers to customers for payment. The Home Office named construction, food delivery, courier work, beauty salons and warehousing when it announced the change, but the wording is not limited to those sectors.

A new employer's guide to right to work checks and a new code of practice both took effect the same day. For any engagement starting on or after 1 October 2026, a civil penalty can be issued where no check was done.

• Do the check before the engagement starts — the same rule that already applied to employees.
• Use one of the three accepted methods: a manual document check, a Home Office online check using a share code, or a certified digital verification service provider.
• Keep the evidence for the length of the engagement and two years after it ends.

Penalties for illegal working run to £45,000 per worker for a first breach and £60,000 per worker for a repeat breach within three years. A correct check completed before the start date is the only statutory excuse — doing it late is the same as not doing it.

Sponsorship Management System: MFA on, Level 2 Users out

• Multi-factor authentication became mandatory on SMS from 3 September 2026.
• From 9 September 2026, no new Level 2 Users can be appointed.
• Existing Level 2 Users must be converted to Level 1 or deactivated by 8 March 2027.

If the only cover for your Level 1 User was a Level 2 User, you now have a single point of failure on an account you need in order to assign a Certificate of Sponsorship. Appoint a second Level 1 User before March, and make sure the multi-factor device belongs to the business rather than to one person who might leave.

What a sponsored hire costs in 2026

• Licence application: £611 for a small or charitable sponsor, £1,682 for a medium or large sponsor.
• Certificate of Sponsorship: £525 for each worker on a Worker route.
• Immigration Skills Charge: £480 a year for small and charitable sponsors, £1,320 a year for medium and large sponsors — a 32% rise that took effect on 16 December 2025, with half those amounts for each additional six months.

For a medium or large employer sponsoring one Skilled Worker for three years, that is roughly £4,500 in Home Office fees before the worker pays anything towards their own visa or the immigration health surcharge. It belongs in the budget at the point you write the job advert, not after the offer.

Skill, salary and English

• Skilled Worker roles have had to sit at RQF level 6 — graduate level — since 22 July 2025, apart from occupations on the Home Office exception lists.
• The general salary threshold is £41,700 for Certificates of Sponsorship assigned on or after 22 July 2025, with lower options for new entrants, health and care roles and jobs on national pay scales.
• The English language requirement rose from B1 to B2 on 8 January 2026.

Which salary threshold applies is fixed by the date the Certificate of Sponsorship was assigned, not the date the worker applied. Record on the file which salary option you relied on — if you cannot show it at a compliance visit, the officer will treat it as not met.

Five things to do this month

• List every person who works for you under something other than an employment contract, and check whether a right to work check exists for each one.
• Appoint or confirm a second Level 1 User, and diary the Level 2 conversion deadline of 8 March 2027.
• Re-run your sponsored worker files against the current salary thresholds, and record the option used for each.
• Add the new Immigration Skills Charge rates to your cost model for any role you are about to advertise.
• Check that follow-up right to work checks and Certificate of Sponsorship end dates sit in a shared diary, not in one person's inbox.